"Discussion Draft" Relating to Estate Valuation Freezes: Hearing Before the Committee on Ways and Means, House of Representatives, One Hundred First Congress, Second Session, April 24, 1990U.S. Government Printing Office, 1990 - 424 lappuses |
No grāmatas satura
1.–5. rezultāts no 98.
61. lappuse
... child each owned 20 % of a corporation and are subject to a shareholder's agreement entered into for a business purpose providing that upon a shareholder's death the company must buy and the shareholder's estate must sell all of the ...
... child each owned 20 % of a corporation and are subject to a shareholder's agreement entered into for a business purpose providing that upon a shareholder's death the company must buy and the shareholder's estate must sell all of the ...
62. lappuse
... child not active in the family business and common stock to a child who is active in the family business . The answer may depend upon a number of incidental factors such as the order of the two gifts , whether the gifts are considered ...
... child not active in the family business and common stock to a child who is active in the family business . The answer may depend upon a number of incidental factors such as the order of the two gifts , whether the gifts are considered ...
63. lappuse
... child owns the common stock . If the corporation has some bad times and is unable to pay the preferred stock ... child where common stock ownership is the inducement the child needs to persevere with the company . joint task force ...
... child owns the common stock . If the corporation has some bad times and is unable to pay the preferred stock ... child where common stock ownership is the inducement the child needs to persevere with the company . joint task force ...
67. lappuse
... child owns a business in a corporation that is a retail busi- ness , which is leasing the real estate used in the business from a third party , it would be quite common for the rental to be based as a percentage of sales . If the parent ...
... child owns a business in a corporation that is a retail busi- ness , which is leasing the real estate used in the business from a third party , it would be quite common for the rental to be based as a percentage of sales . If the parent ...
68. lappuse
... child is not in the business and is very angry that such child is not receiv- ing any income from the business , so the business is recapitalized with the parent and the inactive child taking preferred . Expecting the dividends to be ...
... child is not in the business and is very angry that such child is not receiv- ing any income from the business , so the business is recapitalized with the parent and the inactive child taking preferred . Expecting the dividends to be ...
Citi izdevumi - Skatīt visu
Bieži izmantoti vārdi un frāzes
amount apply approach assets Association National believe business owners buy-sell agreements cash Chapter 14 closely held business closely-held Committee common stock complex concern Congress Contractors corporation current law death debt deemed gift rule determined discretionary rights discussion draft Distributors Association dividend effect election enacted enterprise entity estate and gift estate freeze estate planning estate tax fair market value family business family members family-owned businesses firm future appreciation gift tax GRIT insolvency Internal Revenue Code Internal Revenue Service issue joint purchases lease legislation liquidation market rate million National Association option ownership paid parent partnership interest percent preferred equity preferred stock problem qualified fixed payments recapitalization replacement proposal result retained interest shareholders SMACNA small business specially valued spouse statement statute of limitations statutory taxation taxpayers term interest transactions transferor transferred interest Treasury treated trust valuation abuses valuation freezes valued at zero
Populāri fragmenti
55. lappuse - Committee of the Section of Real Property, Probate and Trust Law of the American Bar Association WILLIAM P.
60. lappuse - The fair market value is the price at which the property would change hands between a willing buyer and a willing seller, neither being under any compulsion to buy or sell and both having reasonable knowledge of relevant facts.
175. lappuse - Mr. Chairman and members of the Ways and Means Committee, I am a manufacturer from Missouri and Louisiana.
190. lappuse - Even if the decedent is not free to dispose of the underlying securities at other than the option or contract price, such price will be disregarded in determining the value of the securities unless it is determined under the circumstances of the particular case that the agreement represents a bona fide business arrangement and not a device to pass the decedent's shares to the natural objects of his bounty for less than an adequate and full consideration in money or money's worth. (i) Stock sold "ex-dividend.
318. lappuse - Where, on the lapse of time, on the occurrence of an event or contingency, or on the failure of an event or contingency to occur...
1. lappuse - In view of the limited time available to hear witnesses, the Subcommittee may not be able to accommodate all requests to be heard. Those persons and organizations not scheduled...
24. lappuse - Section 1015 (relating 16 to basis of property acquired by gift) is amended by adding at 17 the end thereof the following new subsection: 18 "(f) SPECIAL VALUATION RULES TO APPLY.
96. lappuse - IRS will be barred from filing suit for unpaid taxes or for tax deficiencies due to higher government valuations of the gifts. If a taxpayer omits includable gifts amounting to more than 25 percent of the total amount of gifts stated in the return, the statute of limitations is extended to six years.
165. lappuse - ... disregarded in determining the value of the securities unless it is determined under the circumstances of the particular case that the agreement represents a bona fide business arrangement and not a device to pass the decedent's shares to the natural objects of his bounty for less than an adequate and full consideration in money or money's worth. The Regulation permits Treasury to ignore options in buy-sells which have an estate planning motive rather than a business motive. For example, the...
125. lappuse - indefeasibly fixed" are drawn from a Model Disclaimer Act drafted by a Special Committee on Disclaimer Legislation of the Real Property, Probate and Trust Law Section of the American Bar Association. The Draft omits the words "both in quality and quantity" in the Model Disclaimer Act as unnecessary.